There is evidence that the company publishes statements against corruption and in support of ethical business practices, which are endorsed by senior figures other than the company leadership. Publicly available statements made by the company\u2019s leadership are indirect in nature. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company has anti-bribery and corruption policies which apply to all employees, including those working for subdiaries and other controlled entities, as well as executive and non-executive directors. There is evidence that these policies explicitly prohibit bribery and commercial bribery. <\/p>\n
However, there is no evidence that the company's policies prohibit facilitation payments or payments to public officials.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that the company\u2019s board of directors and its audit commitee provide oversight of its anti-corruption programme. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that the company\u2019s Chief Vigilance Officer has responsibility for implementing and managing all anti-corruption activities at the company. There is evidence of reporting and feedback activities between the Chief Vigilance Officer and the company\u2019s Chairman of the Board of Directors. <\/p>\n
However, evidence suggests that the Chief Vigilance Officer is not a senior executive. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of its anti-bribery and corruption programme. There is evidence that the results of risk assessments are reviewed by the board on at least an annual basis. There is additional evidence that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2018s entire anti-corruption programme is subject to a regular audit and review process to ensure maximum efficacy and that it is consistent with best practice and the business risks facing the company, including provisions for continuous improvement. There is also evidence that audit findings are presented to the board, with clear ownership assigned to units and\/or individuals for planned updates and improvements to the programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
The company publicly commits to investigating incidents promptly, independently and objectively. There is evidence that the company takes steps to ensure the independence of its investigations and it commits to establishing root causes, putting in place remediation plans and reporting investigative findings to senior management and the board. For whistleblowing cases, there is evidence that there is a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome, and that the company commits to ensure whistleblowers are informed of the outcome, if they so wish. There is also evidence that the company\u2019s Vigilance Commission receives and reviews summary information of all incidents and their status in the organisation and its subsidiaries, on at least an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of its internal investigations by ensuring that investigative staff are adequately trained. <\/p>\n
However, it is not clear that the company assures itself of the quality of both incident investigations and whistleblowing cases. Additionally, while there is some evidence suggesting that the company reviews its investigative procedures, it is unclear if this occurs at least every three years or in response to any changes in the regulatory environment. Furthermore, there is no evidence to suggest that the company has a system in place for escalating complaints about the investigative process itself. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company reports instances of corruption to the board of directors. The company indicates that its Chief Vigilance Officer is responsible for referring material findings to the relevant authorities<\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publishes high-level data from ethical or bribery and corruption-related incidents and investigations involving company employees at all levels. The publicly available data includes the number of reports received, the number of investigations launched and the number of disciplinary actions brought against employees. The data covers the most recent reporting year.<\/p>\n
However, there is no evidence that the company disaggregates its data to indicate the number of reports received via whistleblowing channels. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy, including the whistleblowing options available to employees.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear how frequently employees must undertake refresher training and whether this is at least every two years. The company also does not expressly state in publcly available information that all employees across its operations and countries of operation must complete training, and that it is available in all relevant languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence indicating that the company provides tailored anti-bribery and corruption training to employees identified as filling high risk positions, as well as executives and board members.<\/p>\n
However, there is no evidence that training is provided for middle management or that the training for these groups is refreshed annually.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is insufficient evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption and communications training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company makes a public commitment to support and protect those who refuse to act unethically in situations which result in lost business for the company.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company operates whistleblowing and incident reporting channels, which are open to all employees, as well as third parties, contractors and joint venture partners. There is evidence that these channels allow for confidential reporting.<\/p>\n
However, evidence indicates that the company only offers internally operated channels that do not allow for anonymous reporting. It is also unclear if the company also operates advice channels. There is no evidence that the company\u2019s reporting channels are available in all countries of operation and in multiple languages. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company operates whistleblowing and incident reporting channels, which are open to all employees, as well as third parties, contractors and joint venture partners. These channels allow for confidential reporting.<\/p>\n
However, evidence indicates that the company only offers internally operated channels that do not allow for anonymous reporting. It is also unclear if the company also operates advice channels. There is no evidence that the company\u2019s reporting channels are available in all countries of operation and in multiple languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has policies covering conflicts of interest, actual, potential and perceived, which apply to all employees, board members, and employees of the wider corporate group, as well as contractors and third parties. These policies cover potential conflicts of interest including personal relationships, financial interests and outside employment, as well as those linked to government relationships<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
The company states that all employees must report if a close relative has a role at a company in a business relationship with the company, and that board members must also declare interests which could constitute a conflict of interest.<\/p>\n
However, the company cannot receive a score of \u20181\u2019 as there is insufficient evidence that the company has in place procedures to identify, declare and manage all types of conflicts of interest across the organisation. There is also no evidence of a senior body or individual with responsibility for managing and overseeing the resolution of conflicts of interest within the organisation.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is evidence that the company, an SOE, has a policy, based on government guidelines, which regulates the process by which its directors may join public sector companies. However, the company receives a score of \u20180\u2019 because there is no evidence that it has a policy regulating the processes by which it might hire current or former public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
The company publishes a clear statement that it prohibits corporate political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":""},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy covering charitable donations, in order to ensure that they are free from corruption. These measures include implementing criteria for donations and senior sign off. There is evidence that the company additionally discloses certain details of its philanthropic activities.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
The company publishes a commitment to engage in public policy development in adherence to all laws and regulations but publishes insufficient information to receive a score of \u20181\u2019. There is no evidence that the company has a clear policy on responsible lobbying which goes beyond adhering to laws. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedures on the giving and receipt of gifts and hospitality, to ensure that they are bona fide and not used for corrupt purposes. The company explicitly addresses the risks associated with gifts given to, and received from, government officials. The company states that all gifts and hospitality given and received must be recorded and submitted. <\/p>\n
However, there is no explicit evidence that these records are stored in a dedicated central repository accessible to those responsible for overseeing the policy. Although the company\u2019s Conduct Discipline and Appeal Rules document sets financial thresholds for different kinds of gifts, this document is dated in 1984 and so it is unclear whether these financial thresholds remain relevant. <\/p>\n"},{"question":82,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires the involvement of its procurement department in the establishment of new suppliers and that this department is ultimately responsible for providing oversight of the company's supplier base. There is evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct corruption-risk based due diligence on all suppliers. There is evidence to suggest that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated. <\/p>\n
However, there is no evidence to suggest that highest risk suppliers are subject to enhanced due diligence, or that the company seeks to independently verify suppliers\u2018 beneficial ownership. Additionally, although there is some evidence of continuous monitoring of suppliers, there is no clear evidence that the company conducts due diligence on all suppliers at least every two years and\/or when there is a change in the business relationship. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that all its suppliers have adequate anti-bribery and corruption policies and procedures in place, by way of requiring suppliers to sign an Integrity Pact at the bid stage. This agreement obliges suppliers to have adequate anti-corruption standards and policies and to abide by all anti-corruption laws and regulations. <\/p>\n
However, there is no evidence that the company audits or reviews each supplier\u2019s anti-corruption policies or programme. There is also no evidence that the company requires that all suppliers must have policies prohibiting facilitation payments, as well as policies which cover conflicts of interest, gifts & hospitality, and whistleblowing;
\nAdditionally, there is no evidence as to whether this assurance is only conducted when onboarding new suppliers or also when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. <\/p>\n
However, this evidence is in the form of a simple statement and there is no evidence of how the company would achieve this in practice.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has a policy covering the use third party consultants, without referring specifically to the term \u2018agents\u2019. This policy addresses the corruption risks associated with the use of external consultants and stipulates specific controls to mitigate these risks. The company also explicitly commits to establishing and verifying that their use, in each case, necessary to perform a legitimate business function.<\/p>\n
However, the company does not clearly specify whether the policy also applies to subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries but does not specify that it includes audit and termination rights in these contracts.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for and\/or on behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
The company states that it accounts for anti-bribery and corruption considerations when entering into a joint venture, and obliges all joint venture partners to adhere to its anti-bribery and corruption policies. There is further evidence that it includes anti-corruption clauses in its contracts with joint venture partners. <\/p>\n
However, there is no evidence that the company takes steps to detect, control and prevent breaches through the inclusion of audit and termination rights in its contracts with joint venture partners. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
The company states that it will communicate the importance of anti-corruption activities to all partners and third parties but there is no evidence that it commits to take an active role in preventing bribery and corruption in all of its joint ventures. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company addresses the corruption risks associated with offset contracts, and there is no evidence that a dedicated body, department or team is responsible for monitoring the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company\u2019s offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the beneficiaries of its offset obligations.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, or that risk assessment procedures are used to inform the company\u2019s operations in high risk markets<\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
The company publishes a full list of its fully consolidated subsidiaries and non-fully consolidated holdings, including joint ventures and related entities. For all entities, the company discloses its percentage ownership, the country of incorporation and countries of operation. There is evidence that this list is current and updated on at least an annual basis. The data is also accompanied by a statement that it is complete at the time of publication to the best of the company\u2019s knowledge.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses all shareholders with a stake in the company or voting rights of 25% or above, alongside each entity\u2019s percentage ownership in the company. The company is also publicly traded on two Indian stock exchanges.<\/p>\n
However, the company receives a score of \u20181\u2019 because the company does not disclose its beneficial ownership information on a freely available and accessible public register.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company discloses the customer of at least 50% of its defence sales.<\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
The SOE publishes a percentage breakdown of its shareholder voting rights for its sole shareholder with a stake greater than 25%.<\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
There is evidence that the SOE publishes some information about its commercial and public policy objectives. <\/p>\n
However, the detail around them in publicly available information is limited and it is unclear if they are updated on at least an annual basis.<\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
The SOE is open and clear about the composition of its board and provides details of its board members, identifying each member as a state representative, executive or an independent director. The company also states that all directors are appointed directly by India\u2019s Ministry of Defence. The company additionally discloses, as per regulatory requirements, that no newly-appointed director holds shares in the company.<\/p>\n
The SOE receives a score of \u20181\u2019 because there is no evidence that it discloses information regarding directors\u2019 nomination process or the criteria for nomination. Additionally, there is no evidence to clarify if existing directors are shareholders. <\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
The SOE discloses the composition of its audit committee and indicates that it is composed solely of independent directors.<\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
There is no evidence that the SOE publishes any details about its management of asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/829","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies"}],"about":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/types\/companies"}],"wp:attachment":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/media?parent=829"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=829"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}